Delhi High Court

Union of India directed to decide representations concerning unauthorized use of "India" by sports bodies.

Kho Kho Federation Of India vs Union Of India And Ors

Delhi High CourtJUDGMENT: March 13, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner, Kho Kho Federation of India (KKFI), claiming to be the recognized National Sports Federation (NSF), sought directions against the Union of India to take action against Respondent No. 2, Kho Kho India (KKI).

Source reference: para. 3-4

The Petitioner alleged that KKI was violating sports regulations by using the term "India" in its name and portraying itself as the official body for Kho Kho.

Source reference: para. 3

The Petitioner argued that its recognition as an NSF, which lasted through 2025, should be deemed to continue into 2026 unless specifically revoked.

Source reference: para. 7

Respondent No. 2 contended that it is the only organization with international recognition under the Olympic Movement and that its own application for NSF status for 2026 is currently pending consideration by the Union.

Source reference: para. 6

The Petitioner had previously filed representations regarding this dispute with the Union of India on 15.01.2026 and 20.01.2026.

Source reference: para. 8
02

Issues

Whether the use of the term "India" by Respondent No. 2 violates the National Sports Development Code, 2011, and the National Sports Governance Act, 2025

Source reference: para. 3-4

Whether a recognized NSF’s status is deemed to continue into a new calendar year (2026) in the absence of a specific revocation

Source reference: para. 7

Whether the Court should adjudicate on the merits of NSF recognition while representations are pending before the Union of India

Source reference: para. 8
03

Law Applied

The Court referred to the National Sports Development Code, 2011 and the National Sports Governance Act, 2025, which govern the recognition of National Sports Federations and the authorized use of the term "India" by sports associations.

Source reference: para. 3-4

The Court further noted the precedent set in Maharashtra Carrom Association v. Union of India & Anr. (2025:DHC:9515), wherein the Court restrained a non-recognized federation from using the expressions "India" or "Indian" in its name, logo, or competitions.

Source reference: para. 5
04

Reasoning

The Court refrained from examining the substantive merits of the dispute regarding which entity should be recognized as the NSF for the year 2026.

Source reference: para. 8

It observed that the Union of India is currently seized of the competing claims from both the Petitioner and Respondent No. 2.

Source reference: para. 6-7

Since the Petitioner had already submitted a representation (15.01.2026) and a reminder (20.01.2026) to the Union of India which were still pending, the Court found it "apposite" to allow the executive to decide the matter first.

Source reference: para. 8

By directing a time-bound disposal of these representations, the Court applied the principle of exhaustion of administrative remedies before judicial intervention, thereby connecting the statutory requirements of the Sports Code to the pending administrative process.

Source reference: para. 8
05

Holding

The Court disposed of the petition without expressing an opinion on the merits of the case.

It directed the Union of India to decide the Petitioner’s representation dated 15.01.2026 and the reminder dated 20.01.2026 in accordance with the law within four weeks from the receipt of the order.

Source reference: para. 8

All rights and contentions of the parties were left open.

Source reference: para. 10
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Kho Kho Federation Of IndiavsUnion Of India And Ors

Delhi High Court · March 13, 2026

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